Privacy Policy

Last updated: 5 August 2026

1. Introduction

A.P. Owning Cyprus Ltd, trading as Owning Cyprus, respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store and disclose personal data when you:

  • Visit or use the Owning Cyprus website;
  • Create or use an account;
  • Enquire about a property;
  • Request a property viewing;
  • Contact us by telephone, email, contact form, WhatsApp or another communication method;
  • Ask us to sell, rent, advertise or manage a property;
  • Enter into negotiations or a business relationship with us; or
  • Use any other real-estate service provided by Owning Cyprus.

This Policy applies to website visitors, prospective buyers, purchasers, prospective tenants, tenants, landlords, property owners, sellers, developers, authorised representatives and other persons whose personal data we process.

2. Who We Are

The data controller responsible for your personal data is:

A.P. Owning Cyprus Ltd
Trading as: Owning Cyprus
Licensed Real Estate Agency
Company Registration Number: HE 494645
Real Estate Agency Registration Number: 1398
Real Estate Agency Licence Number: 439/E
Registered Office: 19, Xenofontos street 8020 Paphos
Telephone: +357 99593899
Email: info@owningcyprus.com

References in this Policy to “Owning Cyprus”, “we”, “us” or “our” mean A.P. Owning Cyprus Ltd.

3. Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data.

Identity and contact information

This may include:

  • Full name;
  • Postal or residential address;
  • Email address;
  • Telephone number;
  • Date of birth;
  • Nationality;
  • Identification or passport details;
  • Company name and position;
  • Details of an authorised representative; and
  • Preferred method of communication.

Account information

Where website accounts are available, we may collect:

  • Username;
  • Encrypted password;
  • Account activity;
  • Saved or favourite properties;
  • Property alerts;
  • Communication preferences; and
  • Account login and security information.

We do not have access to your password in readable form.

Property enquiry and preference information

This may include:

  • Properties viewed, saved or requested;
  • Preferred property type;
  • Preferred location;
  • Purchase or rental budget;
  • Intended use of the property;
  • Preferred viewing date and time;
  • Financing requirements;
  • Messages and questions submitted to us; and
  • Information about your property search.

Property-owner and listing information

Where you ask us to advertise, sell, rent or otherwise deal with a property, we may collect:

  • Property address and location;
  • Ownership information;
  • Title-deed information;
  • Planning and building information;
  • Property photographs, plans and measurements;
  • Rental, tenancy or occupancy information;
  • Asking price and transaction instructions;
  • Mortgage, charge or encumbrance information;
  • Utility and maintenance information; and
  • Documents required to verify your authority to act in relation to the property.

Transaction and financial information

Where relevant to a proposed or completed transaction, we may collect:

  • Offer and reservation information;
  • Purchase or rental price;
  • Deposit and payment information;
  • Bank account details;
  • Invoices, receipts and commission information;
  • Mortgage or financing information;
  • Source-of-funds information; and
  • Information relating to a property transaction.

We do not normally collect complete payment-card details directly through the Website. Where electronic payment services are used, payment information may be processed by the relevant payment provider.

Identification and compliance information

Where required by law or appropriate for a property transaction, we may collect information for customer-identification, due-diligence, anti-money-laundering and sanctions-compliance purposes, including:

  • Copies of identification documents;
  • Proof of residential address;
  • Tax identification information;
  • Beneficial ownership information;
  • Source-of-funds or source-of-wealth information;
  • Company incorporation documents;
  • Information regarding directors, shareholders and authorised representatives;
  • Politically exposed person or sanctions-screening information; and
  • Other documentation reasonably required to satisfy legal or regulatory obligations.

Communications

We may retain communications exchanged with you, including:

  • Emails;
  • Contact-form submissions;
  • Telephone call notes;
  • WhatsApp or messaging communications;
  • Viewing requests;
  • Complaints;
  • Feedback; and
  • Records of instructions or consent.

We do not record telephone calls unless you are informed beforehand.

Technical and usage information

When you use the Website, certain information may be collected automatically, including:

  • Internet Protocol address;
  • Browser type and version;
  • Device type;
  • Operating system;
  • Language and time-zone settings;
  • Pages visited;
  • Date and time of visits;
  • Referring website;
  • Website activity and interaction information;
  • Login and security logs; and
  • Cookie or similar technology identifiers.

Marketing information

This may include:

  • Whether you agreed to receive property alerts or marketing communications;
  • Your preferred property categories;
  • Your communication preferences; and
  • Records of consent, withdrawal or unsubscribing.

4. How We Obtain Personal Data

We may obtain personal data:

  • Directly from you;
  • From a family member, representative or person acting on your behalf;
  • From property owners, sellers, landlords, developers or tenants;
  • From another estate agent or property professional;
  • From lawyers, surveyors, architects, engineers, valuers, accountants, banks or mortgage advisers;
  • From publicly accessible registers, government departments or other lawful public sources;
  • From sanctions, compliance and customer-verification providers;
  • Through your use of the Website; or
  • From third-party platforms through which you contact us or enquire about a property.

Where another person provides us with your personal data, that person must have lawful authority to do so.

5. Why We Use Personal Data

We use personal data for the purposes described below.

Responding to enquiries and arranging viewings

We process your information to:

  • Respond to your questions;
  • Provide property information;
  • Arrange, confirm or reschedule property viewings;
  • Communicate with property owners, landlords or their representatives; and
  • Recommend potentially suitable properties.

The legal basis is taking steps at your request before entering into a contract and our legitimate interest in providing real-estate services and responding to enquiries.

Providing real-estate agency services

We process personal data to:

  • Advertise properties;
  • Introduce prospective buyers or tenants;
  • Arrange and conduct viewings;
  • Receive and communicate offers;
  • Negotiate between parties;
  • prepare agency, reservation or related documentation;
  • Assist with the progression of a sale or rental;
  • Manage our relationship with property owners and clients; and
  • Calculate and collect fees or commissions.

The legal basis is the performance of a contract, taking steps before entering into a contract and our legitimate interest in providing and managing our services.

Managing website accounts

We may process account information to:

  • Register and authenticate users;
  • Maintain saved properties and preferences;
  • Provide property alerts;
  • Protect accounts against unauthorised access; and
  • Provide account-related support.

The legal basis is the performance of our services and our legitimate interest in operating a secure and functional Website.

Legal and regulatory compliance

We may process personal data to:

  • Verify identities;
  • Conduct customer due diligence;
  • Establish beneficial ownership;
  • Carry out sanctions or politically exposed person checks;
  • Prevent money laundering, terrorist financing, fraud and other unlawful activity;
  • Maintain records required by law;
  • Respond to lawful requests from authorities; and
  • Satisfy tax, accounting, corporate and regulatory obligations.

The legal basis is compliance with legal obligations and, where applicable, our legitimate interest in preventing fraud and protecting our business.

Protecting legal rights

We may process information to:

  • Establish, exercise or defend legal claims;
  • Resolve complaints or disputes;
  • Enforce agreements;
  • Obtain legal advice;
  • Investigate suspected misconduct; and
  • Protect our property, staff, clients and business.

The legal basis is our legitimate interest in protecting and enforcing our legal rights and complying with legal obligations.

Website operation, security and improvement

We may process technical information to:

  • Operate and maintain the Website;
  • Diagnose technical problems;
  • Prevent spam, attacks, fraud and unauthorised access;
  • Analyse Website performance;
  • Understand how users interact with the Website; and
  • Improve its functionality and usability.

Essential processing is based on our legitimate interest in operating a secure Website. Optional analytics or advertising technologies are used only where permitted by law and, where required, after obtaining consent.

Property alerts and marketing

Where legally permitted, we may use your contact details and property preferences to send:

  • New property listings;
  • Property alerts;
  • Price changes;
  • Market information;
  • Company news; and
  • Information about relevant services.

Where consent is required, marketing will be sent only after you have given that consent. You may unsubscribe at any time.

6. Legitimate Interests

Where we rely on legitimate interests, those interests may include:

  • Operating a licensed real-estate agency;
  • Responding to property enquiries;
  • Matching interested persons with properties;
  • Communicating with clients and property owners;
  • Advertising and promoting properties;
  • Improving our Website and services;
  • Protecting our systems and accounts;
  • Preventing fraud and misuse;
  • Maintaining business records;
  • Recovering amounts owed to us; and
  • Establishing or defending legal claims.

We consider whether our interests are necessary and proportionate and whether they are overridden by your rights and freedoms.

7. Information You Are Required to Provide

Certain information is optional. However, we may be unable to provide a service or proceed with a property transaction where you do not provide information that is:

  • Necessary to respond to your request;
  • Required to arrange a viewing;
  • Required to enter into or perform a contract;
  • Required to verify your identity or authority;
  • Required by anti-money-laundering or other legislation; or
  • Necessary to protect against fraud or unlawful activity.

We will explain when particular information is mandatory.

8. Special Categories of Personal Data

We do not normally request information concerning health, religion, ethnicity, political opinions, trade-union membership, sexual orientation, genetic data or biometric data.

Please do not provide this type of information unless it is genuinely necessary and we have requested it for a lawful purpose.

Where special-category information is processed, we will do so only where a valid legal condition applies and appropriate safeguards are in place.

9. Sharing Personal Data

We do not sell your personal data.

Where necessary and lawful, we may disclose personal data to the following recipients.

Parties to a property transaction

This may include:

  • Property owners;
  • Sellers;
  • Purchasers;
  • Landlords;
  • Tenants;
  • Developers;
  • Authorised representatives; and
  • Other persons directly involved in the proposed transaction.

We disclose only information reasonably necessary for the enquiry, viewing, negotiation or transaction.

Professional advisers and property-service providers

This may include:

  • Lawyers;
  • Accountants;
  • Auditors;
  • Surveyors;
  • Architects;
  • Civil engineers;
  • Property valuers;
  • Insurance providers;
  • Banks;
  • Mortgage advisers;
  • Property managers;
  • Contractors; and
  • Other licensed estate agents.

Service providers

We may use service providers for:

  • Website hosting;
  • Website maintenance;
  • Email delivery;
  • Customer-relationship management;
  • Cloud storage;
  • Data backup;
  • Cybersecurity;
  • Spam protection;
  • Customer verification;
  • Analytics;
  • Mapping;
  • Communications; and
  • Document management.

Service providers acting on our behalf are permitted to process personal data only for authorised purposes and subject to appropriate contractual and confidentiality obligations.

Government and regulatory authorities

We may disclose information where required or permitted by law to:

  • Courts;
  • Police;
  • Tax authorities;
  • Land and planning authorities;
  • Anti-money-laundering authorities;
  • The Real Estate Agents Registration Council;
  • The Commissioner for Personal Data Protection; and
  • Other competent governmental or regulatory bodies.

Business reorganisation

Personal data may be disclosed in connection with a proposed merger, acquisition, restructuring, sale of business or transfer of assets, subject to appropriate confidentiality and data-protection safeguards.

10. Third-Party Website Services

The Website may include or link to third-party services, such as:

  • Google Maps;
  • WhatsApp;
  • Social-media platforms;
  • Video or image services;
  • Property portals;
  • Anti-spam or security services; and
  • External payment or communication providers.

When you choose to interact with a third-party service, that provider may process personal data under its own privacy policy. We do not control the independent processing activities of external providers.

You should review the relevant provider’s privacy information before submitting personal data through an external platform.

11. International Transfers

Some service providers may process or store information outside Cyprus or outside the European Economic Area.

Where personal data are transferred to a country that has not been recognised as providing an adequate level of protection, we will use an appropriate lawful safeguard where required, such as approved standard contractual clauses, or rely on another transfer mechanism permitted by data-protection law. GDPR Chapter V requires appropriate safeguards and enforceable rights for transfers where no adequacy decision applies. (EUR-Lex)

You may contact us for further information about the safeguards relevant to your personal data.

12. Cookies and Similar Technologies

The Website may use cookies and similar technologies to:

  • Enable essential Website functionality;
  • Maintain login sessions;
  • Remember user preferences;
  • Protect forms and accounts;
  • Measure Website performance;
  • Understand Website usage; and
  • Support embedded or third-party services.

Strictly necessary cookies are used where required for the Website to function securely.

Non-essential analytics, advertising or tracking technologies will be used only where legally permitted and, where required, after you have given consent. European data-protection guidance states that consent is generally required for most online tracking methods under the applicable electronic-privacy rules. (Data Protection Commissioner)

You can manage optional cookies through the Website’s cookie settings. Blocking essential cookies through your browser may prevent parts of the Website from working correctly.

Further information should be provided in our separate Cookie Policy.

13. Data Retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including satisfying legal, accounting, regulatory and reporting obligations.

The retention period depends on:

  • The nature and sensitivity of the information;
  • The purpose for which it is processed;
  • Whether an enquiry developed into a business relationship;
  • Applicable contractual obligations;
  • Legal limitation periods;
  • Regulatory and record-keeping obligations;
  • The risk of harm from unauthorised use or disclosure; and
  • Whether the information is required for a complaint, investigation or legal claim.

As a general policy:

  • Enquiries that do not result in a transaction may ordinarily be retained for up to 24 months after the last meaningful communication;
  • Website account information may be retained while the account remains active and for a reasonable period after closure;
  • Property-listing information may be retained while the property is marketed and afterwards where necessary for records, disputes or legal obligations;
  • Marketing information is retained until you unsubscribe, withdraw consent or the information is no longer reasonably required;
  • Security and technical logs are retained for a limited period appropriate to investigating misuse and protecting the Website;
  • Contractual, transaction, tax and accounting records are retained for the applicable statutory periods; and
  • Customer-identification and transaction records subject to Cyprus anti-money-laundering requirements may need to be retained for at least five years after the end of the business relationship or the date of an occasional transaction. (Cyprus Law)

Information may be retained for longer where required by law, requested by a competent authority or necessary for ongoing legal proceedings.

When personal data are no longer required, they will be securely deleted, destroyed or anonymised.

14. Data Security

We use reasonable technical and organisational measures designed to protect personal data against:

  • Accidental or unlawful destruction;
  • Loss;
  • Alteration;
  • Unauthorised disclosure;
  • Unauthorised access; and
  • Other unlawful processing.

Measures may include access controls, password protection, encrypted connections, system monitoring, backups, software updates, staff confidentiality obligations and restrictions on access according to business need.

No website, email system or method of electronic transmission is completely secure. You should avoid sending unnecessary identification documents, bank details or other sensitive information through ordinary email, contact forms or messaging services unless we have requested them and provided an appropriate method.

15. Your Data-Protection Rights

Subject to the conditions and exceptions in applicable law, you may have the right to:

  • Request confirmation as to whether we process your personal data;
  • Request access to your personal data;
  • Request correction of inaccurate or incomplete information;
  • Request deletion of personal data;
  • Request restriction of processing;
  • Object to processing based on legitimate interests;
  • Object at any time to direct marketing;
  • Request data portability where applicable;
  • Withdraw consent where processing is based on consent;
  • Lodge a complaint with a supervisory authority; and
  • Not be subject to certain decisions based solely on automated processing that produce legal or similarly significant effects.

These rights are not absolute. For example, we may need to retain information to comply with a legal obligation, establish or defend a legal claim or satisfy anti-money-laundering requirements.

To exercise a right, contact:

A.P. Owning Cyprus Ltd
Email: info@owningcyprus.com

Please state clearly which right you wish to exercise. We may request reasonable information to verify your identity and protect personal data against unauthorised disclosure.

Under the GDPR, requests must generally be handled without undue delay and within one month, although an extension of up to two additional months may be permitted for complex or numerous requests. (EUR-Lex)

16. Marketing Preferences

You may stop receiving marketing communications at any time by:

  • Using the unsubscribe option included in the communication;
  • Changing your account or property-alert preferences, where available; or
  • Contacting us at info@owningcyprus.com.

Unsubscribing from marketing will not prevent us from sending communications necessary for an active enquiry, viewing, contract, property transaction or legal obligation.

17. Automated Decision-Making

Owning Cyprus does not currently use personal data to make decisions based solely on automated processing that produce legal effects or similarly significantly affect individuals.

We may use basic automated functions, such as property alerts based on criteria selected by you, spam detection or Website-security checks. These functions do not independently decide whether you may purchase, rent or list a property.

18. Children’s Privacy

Our real-estate services are not directed at children, and we do not knowingly collect children’s personal data for property transactions.

Where a minor is legally involved in a transaction, information will be processed only where necessary, through an appropriate parent, guardian, legal representative or professional adviser and in accordance with applicable law.

19. Third-Party Links

The Website may contain links to websites operated by other organisations.

We are not responsible for the privacy, security or content of external websites. You should review the privacy policy of each external website before providing personal data.

20. Changes to This Privacy Policy

We may update this Privacy Policy where:

  • Our services change;
  • Our Website functionality changes;
  • We introduce or remove service providers;
  • Our processing activities change; or
  • Legal or regulatory requirements change.

The latest version will be published on the Website with the updated revision date.

Where a change materially affects how we use personal data, we will take reasonable steps to provide additional notice where appropriate.

21. Complaints

We encourage you to contact us first so that we can attempt to resolve your concern.

You also have the right to lodge a complaint with the Cyprus supervisory authority:

Office of the Commissioner for Personal Data Protection
15 Kypranoros Street
1061 Nicosia
Cyprus

Postal address:
P.O. Box 23378
1682 Nicosia
Cyprus

Telephone: +357 22 818456

Every data subject has the right to lodge a complaint with the Commissioner. (Data Protection Commissioner)